Newsletter
| September 22, 2009
Focus on Tax Controversy and Litigation (Volume II, Issue 7)
In this issue:
- Details of the UBS-IRS Settlement Released
- Current Developments Related to the US Government’s Focus on Offshore Tax Evasion
- IRS Issues Revenue Ruling on Risk Distribution in the Reinsurance Context
-
Pierre v. Commissioner: A Single-Member LLC Is Not Disregarded for Gift Tax Purposes
- Recent Cases Involving the Extended Limitations Period for Substantial Omissions of Gross Income
- Aloe Vera of America, Inc. v. United States: Ninth Circuit Vacates and Remands Case on Improper Disclosures Made Under the US-Japan Tax Treaty
- Tax Court Rules that Res Judicata Does Not Prohibit the IRS From Recapturing an NOL Refund Even Though the Tax Years at Issue Had Already Been Litigated
- Tax Court Denies Motion to Compel Disclosure of Tax Opinions Collected by IRS
- Court Denies Refund Related to Repatriation of Offshore Earnings
- Dewey & LeBoeuf Congratulates NYU LL.M. in Taxation Graduates
For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:
This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
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